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731 KB
Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
731 KB
Summary
This legal document is a filing on behalf of Ms. Maxwell arguing against the government's proposal for a limited evidentiary hearing concerning Juror No. 50. The defense contends that the juror's alleged false answers necessitate a reversal, citing Supreme Court precedent, and that Ms. Maxwell has a constitutional right to a full adversarial hearing, not the narrow one proposed by the government. The filing draws parallels to the United States v. Daugerdas case to support its claim for a new trial.
People (5)
| Name | Role | Context |
|---|---|---|
| Martinez-Salazar | Party in a legal case |
Mentioned in the case name United States v. Martinez-Salazar, cited as a Supreme Court precedent.
|
| Juror No. 50 | Juror |
A juror whose alleged false answers and presence on the jury are the subject of the legal argument for a reversal.
|
| Ms. Maxwell | Defendant |
The defendant in the current case, whose constitutional rights are being argued in this document.
|
| Daugerdas | Party in a legal case |
Mentioned in the case name United States v. Daugerdas, cited as a precedent.
|
| William H. Pauly III | Honorable (Judge) |
Presiding judge in the cited case United States v. Daugerdas, Case No. 09 Cr. 581.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Supreme Court | government agency |
Cited as having held a ruling in the case United States v. Martinez-Salazar.
|
| Court | government agency |
Refers to the court hearing the current case involving Ms. Maxwell.
|
Timeline (2 events)
An evidentiary hearing is being discussed, with the government requesting a narrow scope and the defense (Ms. Maxwell) arguing for a full adversarial hearing.
Ms. Maxwell's trial, which is argued to have required 12 fair and impartial jurors.
Relationships (2)
The document describes the legal system as an "adversarial system" and details the opposing arguments of Ms. Maxwell's defense and the government regarding an evidentiary hearing.
The presence of Juror No. 50 on the jury for Ms. Maxwell's trial is the central issue of this legal argument, with the defense claiming his presence requires a reversal of the verdict.
Key Quotes (5)
"the seating of any juror who should have been dismissed for cause . . . require[s] reversal."Source
— Supreme Court
(Quoted from the ruling in United States v. Martinez-Salazar, 528 U.S. at 316, to support the argument for reversal due to Juror No. 50's presence.)
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Quote #1
"conceal[ed] personal background material so analogous to the case on trial"Source
— the government
(A quote from the government's own argument in the precedent case of Daugerdas, used here to describe a juror who had implied bias.)
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Quote #2
"bias [] implied as a matter of law"Source
— the government
(A quote from the government's argument in the Daugerdas case, used to argue that a defendant would be entitled to a new trial under such circumstances.)
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Quote #3
"finality"Source
— the government
(A word the government is said to be incanting as a basis for its position, while paying lip service to the requirement of a fair trial.)
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Quote #4
"disfavor"Source
— the government
(A word the government is said to be incanting as a basis for its position, while paying lip service to the requirement of a fair trial.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,177 characters)
Case 1:20-cr-00330-PAE Document 616 Filed 02/24/22 Page 7 of 32
response would have provided a valid basis for a challenge for cause”). That’s because, as the Supreme Court held in United States v. Martinez-Salazar, “the seating of any juror who should have been dismissed for cause . . . require[s] reversal.” 528 U.S. at 316. Thus, irrespective of whether Juror No. 50 deliberately provided false answers to Questions No. 25 and 48 (though the record shows he did), his presence on the jury requires reversal if he was impliedly, inferably, or actually biased.
Second, the government misunderstands this Court’s role during any evidentiary hearing. Ours is an adversarial system, not an inquisitorial system. Ms. Maxwell has a right to present her arguments to the Court, to call material witnesses in support of those arguments, and to confront and cross-examine those witnesses. The government’s request for a narrow and limited hearing in which only Juror No. 50 would testify and only the Court would ask questions flies in the face of this adversarial process. A hearing conducted on the government’s terms would violate Ms. Maxwell’s constitutional right to assistance of counsel, hamstring the search for the truth, and contravene the tradition and precedent of this judicial district. See, e.g., EXHIBIT 3, United States v. Daugerdas, Case No. 09 Cr. 581 (Hon. William H. Pauly III) (Trans. of Motion for New Trial). As the government itself argued in Daugerdas, a juror who “conceal[ed] personal background material so analogous to the case on trial” had “bias [] implied as a matter of law” and the affected defendant therefore would be entitled to a new trial. Doc. 487, p 21, United States v. Daugerdas, No. 1:09-cr-00581-DLC, Sept. 9, 2011. This is just such a case.
The government’s response to Ms. Maxwell’s motion for a new trial elides the stakes involved and the significance of the constitutional right at issue. Ms. Maxwell was on trial for her life. That trial required 12 fair and impartial jurors. While paying lip service to the requirement of a fair trial, the government incants the words “finality” and “disfavor” as a basis
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